NRC-98-0129, Forwards Rev 0 to Fermi 1 SAR, in Response to NRC Comments & Updated Info Re 971215 Application for License Amend. Revised Pages Marked Rev 0,but with Updated Date as NRC Has Not Yet Approved SAR
| ML20153B784 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/15/1998 |
| From: | Gipson D DETROIT EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20153B787 | List: |
| References | |
| CON-NRC-98-0129, CON-NRC-98-129 NUDOCS 9809230242 | |
| Download: ML20153B784 (10) | |
Text
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Douglas R. Gipson Senior Vice President, Nudear Generation Fermi' 6400 North Dixie llwy, Newport, Michigan 48166 Tel:313.586.5201 Fat 313.586.4172 Detroit Edison September 15,1998 NRC-98-0129 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D. C. 20555
References:
- 1) Enrico Fermi Atomic Power Plant, Unit No.1 NRC Docket No. 50-16 NRC License Number DPR-9
- 2) Detroit Edison Letter, NRC-97-0115, l
" Application for a License Amendment - Fermi 1 Safety Analysis Report", dated December 15,1997
- 3) Detroit Edison Letter, NRC-98-0087,
" Voluntary Licensee Event Report No. 98-01, dated May 8,1998
- 4) Detroit Edison Letter, NRC-98-0044,
" Proposed License Amendment to Allow Possession of Special Nuclear Material", dated July 17,1998
Subject:
Revision to Application for a License Amendment -
Fermi 1 Safety Analysis Report Detroit Edison submitted the Fermi 1 Safety Analysis Report (FISAR) (Reference 2) to meet the 1996 Decommissioning Rule. Reference 2 requested a license amendment to modify Part 2.A of the Fermi 1 license to reference the Fermi 1 Safety Analysis Report instead of the six letters constituting the current license basis. This submittal revises the FISAR in response to NRC comments and updated information. The proposed license amendment remains the same. Also, since the FISAR has not yet been approved by the NRC, the revised pages in this submittal are marked Revision 0, but with an updated date.
l The main changes in the revised F1SAR include revising the Quality Assurance Program, as discussed in the July 28,1998 public meeting with the NRC; addressing the tritium 9909230242 980915 7 l
PDR ADOCK 05000016 P
USNRC NRC-98-0129 Page 2 detected in the secondary sodium, as covered in Reference 3; revising the hypothetical secondary sodium accident scenario; adding the additional isotopes identified in the waste water system, as addressed in part in Reference 4 and a March 6,1998 meeting with the NRC; and incorporating a title chante implemented since the original submittal.
Additionally, summation errors in Table 4.1 were corrected.
Detroit Edison requests that the NRC review the revision to the F1SAR and approve the amendment with an implementation period of"within 60 days" to allow final approval of procedure changes required to implemem the change. Detroit Edison will not use the new filar to perform safety evaluations until this amendment is approved and implemented. Prompt NRC review and approval will be appreciated.
Detroit Edison has re-evaluated the proposed change against the criteria of 10 CFR 50.92 and determined that No Significant Hazards Consideration is involved. This evaluation is included in Attachment 1.
The Fermi 1 Review Committee has reviewed and approved this license amendment request, including the revisions to the Fermi 1 Safety Analysis Report. In accordance with 10 CFR 50.91, Detroit Edison is providing a copy of this letter to the State of Michigan.
If there are any questions, please contact Lynne Goodman, Director Fermi 1 at
)
734-586-1205.
Sincerely,
.W Enclosures cc: NRC Regional Administrator, NRC Region III S.W. Brown G.A. Harris P. Lee, NRC Region III D.R. Hahn (Michigan Dept./Public Health)
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.USNRC NRC-98-0129 Page 3 I, DOUGLAS R. GIPSON, do hereby affirm that the foregoing statements are based on facts and circumstances which are true and accurate to the best of my knowledge and belief..
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DOU'GLAS f. GIPSON Senior Vice President On this /[
day of
.1998 before me personally appeared Douglas R. Gipson', bein'g first duly sworn and says that he executed the foregoing as his free act and deed.
Au S R6 otary Public ROSAltE A. ARMITTA l
WTAflYPUBLIC MONROECOUNTY,Mt MYCOM18EEGIENPIRES10f11/99
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l USNRC NRC-98-0129 Page 4 l
l bec: G. Cerullo P. Fessler D.R. Gipson L.S. Goodman -
P. Marquardt -
J.E. Moyers l
J.E. Conen L
L. Craine R.R. Eberhardt, Jr.
D. Ferencz l
l W.D. Gilbert l
R.A. Janssens l
E.F. Kokosky R. Laubenstein E.F. Madsen l
R. McLenon l
. J.E. Meyers R.A. Newkirk W.T. O'Connor, Jr.
E.M. Page K.W. Sessions E.M. Wilds I
D.R. Williams Information Management (116 NOC) - Fermi 1 Records NRR Chron File (Licensing)
NRC Notebook (Fermi 1) i o
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to NRC-98-0129 Page1 NRC Docket No. 50-16 NRC License No. DPR-9 Enrico Fermi Atomic Power Plant, Unit 1 Description of Proposed Amendment and No Significant Hazards Consideration Review for the Fermi 1 Safety Analysis Report i
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l to NRC-98-0129 Page 2 PROPOSED AMENDMENT Detroit Edison continues to propose that Part 2.A of the Fenni 1 license read as follows:
This amended license applies to the Enrico Fermi Atomic Power Plant, Unit No.1 (the facility) owned by the Detroit Edison Company. The Facility is located at Lagoona Beach, Frenchtown Township, Monroe, Michigan and is described in the Fermi 1 Safety Analysis Report as amended.
SIGNIFICANT HAZARDS CONSIDERATION In accordance with 10CFR50.92, Detroit Edison has made a determination that the proposed amendment involves no significant hazards considerations. To make this determination, Detroit Edison must establish that conduct of activities in accordance with the proposed amendment would not: (1) involve a signiricant increase in the probability or consequences of an accident previously evaluated, i
or (2) create the possibility of a new or different kir! 3 of accident from any accident previously evaluated, or (3) involve a sir, ficant reduction in a margin ofsafety.
The Fermi 1 Safety Analysis Report (FISAR) has been prepared based on the six letters currently referenced in the Fermi 1 license (May 17,1985; July 23,1986; September 15,1986; September 25,1987; September 15,1988; and December 22,1988), information gathered during the decommissioning evaluation completed in 1997, information obtained during the Industrial Safety i
Improvement Program to date, safety evaluations performed since the submittal of the six letters, and the Administrative Controls and Surveillance Procedures Manual. One additional hypothetical accidental analysis was added based on a safety evaluation performed as a result ofidentifying apparent unreacted sodium i
in the secondary sodium storage tanks. A scenario was postulated that was not explicitly addressed in the SAFSTOR licensing basis. The scenario was revised for this submittal to address the tritium detected in the secondary sodium and reaction of sodium hydroxide with carbon dioxide. The safety evaluation concluded that the consequences of the hypothetical secondary sodium analysis were bounded by the previously analyzed primary sodium release and liquid waste tank accidents. The hypothetical secondary sodium scenario is covered in Section 8.4 of the FISAR.
As discussed in the July 15,1997 meeting with the NRD, the existing accident j
analyses were not updated from previous submittals. At the time Reference 2 l
was submitted, the previous analyses were thought to be still bounding since the I:
additional decay in the last decade would result in lower radioactivity concentrations and therefore lower potential doses.
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to NRC-98-0129 Page 3 1
However, in this revision to the FISAR, tritium ~was added to the potential radionuclide inventory released during the postulated sodium accident. Primary sodium tritium inventory was interpolated from the secondary sodium analyses, as addressed in Section 4.1.1 of the FISAR.
A review was performed recently ofliquid waste system water and smear analyses from 1989 through 1998 to date. This review was performed as a result j
ofidentifying a very small amount ofplutonium on smears taken on a pump in the waste water sump. A license amendment request (Reference 4) has been submitted to address the small amount ofplutonium. The review determined some radionuclides were identified in analyses other than the "Co and "'Cs used for the liquid waste accident. The combinations of radionuclides varied in the different analyses, as did the ratios of the radionuclides. Section 4.1.1 of the FISAR was updated to include these radionuclides as being in the facility inventory.
The liquid release accident analyses were not redone. The scenarios and results of the original SAFSTOR liquid release accident analyses are still reported in Section 8. However, a conservative evaluation of the potential maximum offsite dose considering the additional radionuclides in portions of the liquid waste system was performed and the results are reported for Scenario A, the airbome release. Also, the potential maximum water ingestion whole body dose due to the additional radionuclides in portions of the liquid waste system was evaluated for the postulated liquid release to Lake Erie and reported for Scenario B in Section 8. In both cases, the estimated maximum dose increased, but maximum doses remained below 100 mrem.
To determine whether a significant hazards is posed by the proposed amendment, three questions are answered.
1)
Does the proposed change significantly increase the probability or consequences of an accident previously evaluated?
No, the proposed submittal of the Fermi 1 Safety Analysis Report as the facility's licensing basis document does not significantly increase the probability of an accident. The FISAR is a compilation of previously submitted information and other information gathered on the condition of the facility. Compilation of current information and imposition of the new Fire Protection and Quality Assurance Program requirements will not increase the probability of an accident. If anything, the additional controls would reduce the probability of an event. Addition of the hypothetical secondary sodium scenario identifies one possible previously unidentified potential cause of a primary sodium release and/or liquid waste tank release. The current licensing basis letters address the cause of the primary sodium release as being a fire or other catastrophic event and the cause of the liquid waste tank ruptures being possibly an earthquake. Recognition
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to NRC-98-0129 Page 4 of a cause being the reaction of secondary sodium does not significantly increase the probability of a primary sodium release or liquid waste release.
A catastrophic event would still need to occur to cause the postulated scenario, so there is no discemible incmase in the probability of a primary sodium or liquid waste accident compared to the existing licensing basis.
For the reasons discussed above, substituting the FISAR as the licensing basis for Fermi 1 will not significantly increase the probability of an accident.
The proposed submittal of the FISAR as the Fermi 1 licensing basis document will only slightly increase the consequences of an accident.
Consolidating current information on the plant and previous submittals allowed recognition of additional radionuclides present in portions of the liquid waste system and the presence of tritium in the sodium. The tritium quantity was not sufficient to affect the magnitude of the potential sodium release. The maximum dose to the public from releasing all the radioactive material in the sodium is still well below I mrem. The maximum potential dose to a member of the public from a liquid waste release accident did increase, but not significantly. The maximum dose is still well below 1 rem. Therefore, the adoption of the FISAR as the facility's licensing basis will not significantly increase the consequences of an accident at Fermi 1.
2)
Will the proposed amendment create the possibility of a new or different kind of accident from any accident previously analyzed?
No, establishment of the F1SAR as the Fermi 1 licensing basis document will not create a new type of accident. The F1SAR is mainly a compilation of the previous licensing basis documents, information on the facility condition, and additional controls. It does not involve operating in any new type of mode and so cannot create a new or different type of accident. The FISAR does address that radioactive effluent releases may occur. This previously was allowed by the Technical Specifications, but a statement in the previous letters had discussed that releases were not expected during SAFSTOR. Technical Specifications still govem any releases. The new hypothetical secondary sodium accident contained in the FISAR is a sodium accident. One of the existing licensing basis accidents is the primary sodium accident resulting in release of the primary sodium and its activity. The hypothetical secondary sodium accident, as analyzed, may lead to the release of the primary sodium or liquid waste and so it is a potential precursor of an already identified accident (s).
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to NRC-98-0129 Page5 3). Will the proposed change significantly reduce the margin of safety at the facility?
No, adopting the new FISAR as the licensing basis document for Fermi 1 will not decrease the margin of safety. It will establish an up-to-date licensing basis, so future changes can be appropriately evaluated against an updated safety analysis report. The F1SAR better describes the current condition of the plant. No physical changes will be implemented based on the submittal of the F1SAR. Some additional administrative requirements will be established in the new Quality Assurance program and in the need to keep the F1SAR updated biannually. No new types of accidents are discussed in the F1SAR - the discussion of the hypothetical secondary sodium event is a more detailed discussion of what potentially could happen during a catastrophic event leading to a sodium reaction. A total primary sodium release was already established as a licensing basis event.
Because the F1SAR will not, in itself, lead to physical changes, but will be the new standard to which future changes are compared, establishment of this updated document as the Fermi 1 licensing basis will not significantly reduce the margin of safety of the facility.
ENVIRONMENTAL IMPACT Detroit Edison has reviewed the proposed change against the criteria of 10 CFR 51.22 for environmental considerations. The proposed change does not involve a significant hazards consideration, nor significantly change the types or significantly increase the amounts of effluents that may be released off site, nor increase individual or cumulative occupational radiation exposures. Based on the foregoing, Detroit Edison concludes that the proposed amendment meets the criteria given in 10 CFR 51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.
CONCL,USION Based on the evaluations above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by conduct of activities in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the proposed amendment will not be inimical to the common defense and security or the health and safety of the public.
to NRC-98-0129 Page1 1
Revised Pages for Fermi 1 Safety Analysis Report Revision 0 Attached are revised pages to the Fermi.1 Safety Analysis Report which are numbered Rev 0,8/98. Pages that did not change from the original submittal are numbered Rev 0, 12/97. Please use the following list to insert / remove the revised pages.
LOCATION REMOVE INSERT Table of Contents Pages i, ii Pages i, ii List of Effective Pages LEP-1, LEP-2 LEP-1, LEP-2 Section 3 Pages 3-7,3-8 Pages 3-7,3-8 Pages 3-12,3-13,3-14 Pages 3-12,3-13,3-14 Section 4 Pages 4-1,4-2 Pages 4-1,4-2 Table 4.1 Page 4-5 Page 4-5 Section 6 Entire Section Pages 6-1 thru 6-7 (Pages 6-1 thru 6-5)
Section 8 Pages 8-4 thru 8-12 Pages 8-4 thru 8-12